Housing Plus

Housing Plus

Guidance and legal insight for all aspects of housing and community development

By the Housing Group at Ballard Spahr

Tag Archives: IRS

Request for IRS Guidance on LIHTC Issues

Posted in Low Income Housing Tax Credits, Policy
Last week at the annual meeting of the American Bar Association Forum on Affordable Housing and Community Development (Forum), Michael Novey, Associate Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury, encouraged the Tax Credit Equity and Financing Committee of the Forum to consider submitting a request to the IRS for priority… Continue Reading

IRS releases final LIHTC Audit Technique Guide

Posted in Low Income Housing Tax Credits, Tax Credits
Last week, the IRS released a long-anticipated update to its Audit Technique Guide for the low-income housing tax credit (“LIHTC”) program. The guide is intended to assist IRS examiners charged with auditing owners of LIHTC properties, and is the first official update published since 1999. A draft of the updated guide was made available for public… Continue Reading

IRS allocates “National Pool” credits to thirty-five states and Puerto Rico

Posted in Low Income Housing Tax Credits, Tax Credits
Yesterday, the IRS issued Revenue Procedure 2014-52 which provides for the reallocation of $2.59 million of unused national pool low-income housing tax credits (LIHTCs).  The national pool credits were divided among thirty-five states and Puerto Rico, with California receiving the largest allocation of $364,756. Each year the Internal Revenue Service allocates a certain amount of LIHTCs… Continue Reading

Draw down bonds and date of issuance: questions remain with IRS guidance

Posted in Housing Bonds, Multifamily, Tax-Exempt Bonds
For many years multifamily housing apartment projects could be financed with tax-exempt drawn-down bonds and loans with all of the bonds issued pursuant to a draw-down loan being treated as part of a single issue.  The date of issuance for the bonds would be the first date on which the aggregate draws exceeded the lesser… Continue Reading

Restructuring of tax-exempt obligations used to finance affordable housing projects and “tax reissuance”

Posted in Housing Bonds
Restructuring tax-exempt obligations Recently I have assisted several clients restructure the tax-exempt obligations originally issued to finance their affordable housing projects. The purpose of these restructurings has been for anything from reducing the monthly principal and interest payments on the obligation, to converting some of the obligations to a subordinate lien position, to simply making… Continue Reading